The defendant is charged [in count __]
with money laundering in the fourth degree. The statute defining this offense
reads in pertinent part as follows:

a person commits the crime of money
laundering in the fourth degree when (he/she) (exchanges / receives in
exchange), in one or more transactions, one or more monetary instruments derived
from criminal conduct constituting a felony, for one or more other monetary
instruments [or equivalent property,] with the knowledge that the exchange will
<insert as appropriate:>

conceal that the
exchanged monetary instrument or instruments (or equivalent property) is derived
from any criminal activity.

aid a person to
engage in criminal activity.

aid a person to
profit from criminal activity.

aid a person to
benefit from criminal activity.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Exchange of
monetary instrument The first element is that the
defendant (exchanged / received in exchange) any monetary instrument for one or
more other monetary instruments [or equivalent property].

"Monetary
instrument" means coin or currency of the United States or of any other
country, travelers' checks, personal checks, bank checks, money orders,
negotiable investment securities or negotiable instruments in bearer form or
otherwise in such form that title thereto passes upon delivery.

"Equivalent
property" means property that may be readily converted into, or exchanged
for, United States or foreign currency or coin, including gold, silver or
platinum bullion or coins, diamonds, emeralds, rubies, sapphires or other
precious stones, stamps or airline tickets, or any other property that is
intended to be so converted or exchanged.

Element 2 - Derived from
felonious conductThe second element is that the
defendant knew that at least one of the monetary instrument(s) (exchanged /
received) was derived from criminal conduct constituting a felony.1
"Felony" means a criminal offense committed in this state or another
jurisdiction punishable by death or a term of imprisonment exceeding one year.
A person acts "knowingly"
with respect to conduct or circumstances when (he/she) is aware that (his/her)
conduct is of such nature or that such circumstances exist. <See
Knowledge, Instruction 2.3-3.>

Element 3 - KnowledgeThe third element is that the
defendant (exchanged / received) the monetary instrument(s) with the knowledge
that the exchange will <insert as appropriate:>

conceal that the
exchanged monetary instrument or instruments (or equivalent property) is derived
from any criminal activity.

In summary, the state must prove
beyond a reasonable doubt that 1) the defendant (exchanged / received in
exchange) a monetary instrument for one or more monetary instruments [or
equivalent property], 2) (he/she) knew that at least one of the monetary
instruments (exchanged / received in exchange) by the defendant derived from
felonious conduct, and 3) the defendant intended <insert specific allegations>.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of money
laundering in the fourth degree, then you shall find the defendant guilty. On
the other hand, if you unanimously find that the state has failed to prove
beyond a reasonable doubt any of the elements, you shall then find the defendant
not guilty.
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